Сравнителноправен поглед към противоправността при деликтната отговорност
A comparative look at wrongfulness in tort liability

Summary/Abstract: The article takes a comparative approach to the idea of wrongfulness as an element of tort liaiblty and tries to explore it in French, Italian, German, English and Bulgarian law. The concept of wrongfulness is further placed in a broader context of the specific profiles of the given legal systems and the different legal traditions they follow when dealing with tort liaibility. Finally, concluding remarks are made about the benefits of such comparative law analysis to the understanding of wrongfulness in Bulgarian tort law.

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